The magnitude of those mistakes and the degree of willfulness involved will, I think, be key.

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True, there was some evidence of willfulness, but there was other evidence Williams was not.

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The IRS says willfulness can be a conscious effort to avoid learning about FBAR reporting.

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As the central maiden, Simone Messmer made much of the character, playing her enchantment with almost zany willfulness.

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That kind of resilience, or determination, or willfulness reminds me of Julian Newman , the little basketball player who could.

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If the taxpayer has not been so notified, then without delay the taxpayer should retain tax counsel and make a willfulness determination.

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Ignorance of the law is a defense to willfulness.

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Her embodiment of such girlish emotions as curiosity-streaked ardor and such womanly ones as do-or-die willfulness enables her director, Zhang Yimou, to eschew melodramatic inflation while crafting a visually eloquent tribute to rural life.

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Rather, because these programs provided both protection from criminal prosecution and a potentially favorable civil penalty structure, even taxpayers whose conduct did not evidence the willfulness necessary to support a criminal prosecution made voluntary disclosures to attain certainty regarding their civil exposure.

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